PSW GROUP

Business Code of Conduct & Ethics

In Louka u Litvínova, December 9th, 2021

PSW Group (the “Company”) is a Czech based enterprise which specializes in the research and development, recycling and production of Magnesium alloys since 1998. Our mission is to provide excellent quality in products and service and focus on further improvements of new materials in order to meet our customer expectations. We work closely with our suppliers and customers and we focus on continuous innovative solutions in order to protect our health and environment.

The Company is committed to conducting its business with honesty and integrity including the ethical handling of conflicts and apparent conflicts of interest and in compliance with the law.

Therefore, the Company has adopted this Code of Ethics and Business Conduct (the “Code”) intended as a guide to appropriate conduct and setting out acceptable and unacceptable behavior.

Code of Conduct

1. Business Principles

1.1. We conduct all business activities in compliance with applicable laws and regulations and in a manner consistent with our values of integrity, accountability, and responsibility.

1.2. We refuse to engage in any form of bribery, corruption, or unethical business practice. We do not offer, pay, solicit or accept bribes or kickbacks to or from anyone.

1.3. We protect and respect intellectual property rights, including patents, trademarks, copyrights and trade secrets.

1.4. We realize that long-term business is built on trust, mutual respect and contractual obligations. We prefer long-term business relationships and enter into relationships only with those adhering to applicable laws and using financial resources not coming from illegal activities.

1.5. We realize that without the well-being of our Company Personnel we would not be able to meet our standards and deliver the highest quality products to our customers. Therefore, we create a safe working environment built on trust and mutual respect, recognizing and respecting all legitimate rights of our employees. We care about the health of our Company Personnel and strictly comply with the applicable laws on a healthy and injury-free workplace. Our Company Personnel are provided with fair and competitive wages and their working hours never exceed the maximum set out by labor laws applicable in the Czech Republic.

1.6. We recognize the human rights of all people as outlined in the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the International Labour Organization Conventions and Recommendations.

Purchase Terms

Our purchase terms govern all transactions with suppliers and partners. All purchases are conducted in accordance with our ethical standards and legal requirements. Suppliers must comply with applicable environmental, labor, and safety regulations.

Terms and Conditions

All business relationships with PSW Group are subject to our standard terms and conditions. These terms cover payment, delivery, quality requirements, and liability.

Whistleblowing Policy

PSW Group encourages all employees, suppliers, and partners to report any suspected violations of this Code or applicable law. Reports can be made confidentially and without fear of retaliation.

The Company will investigate all reports promptly and take appropriate action where violations are confirmed.

PSW Group — Nadrazni 214, Louka u Litvinova, 435 33 Czech Republic